Configuring Legitimate Interest for IAB TCF 2.2

The General Data Protection Regulation (GDPR) allows for data processing on the Legitimate Interest legal basis.

GDPR Article 6 Section 1f defines Legitimate Interest processing as when:

processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

Within the IAB 2.2 framework Legitimate Interest can be used by registered IAB Vendors as a legal basis for processing data. This means that when the Vendor signs up for the IAB framework, they disclose which IAB 2.2 Purposes they will use for processing data and what legal basis they will use to process that data.

Their choices are Consent and Legitimate Interest. For Consent as a legal basis, the user must provide consent for that Purpose for the Vendor to be able to process data. When a Vendor chooses Legitimate Interest as a purpose of processing, the user does not need to consent for that purpose in order for the vendor to process data.

As a publisher, you may decide to you do not find this legal basis appropriate for a given vendor and therefore wish to prevent them from using Legitimate Interest as a legal basis.

If you decide to allow Vendors to use Legitimate Interest, you need to give the data subject the ability to dispute the Legitimate Interest legal basis of processing. In OneTrust, this is displayed to the end-user as a toggle, checkbox, or button.

You can review the IAB TCF 2.2 policies here.

You can also allow Legitimate Interest by individual vendor. For more information, see Managing the IAB TCF Global Vendor List.

You will also need to ensure that your implementation complies with IAB TCF 2.2 standards. To ensure that you are compliant, see IAB TCF 2.2 Policy Checklist & Custom Text Requirements.


Reason for Processing	Consent	Legitimate Interests
Purpose 1 - Store and/or access information on a device	Yes	No
Purpose 2 - Use limited data to select advertising	Yes	Yes
Purpose 3 - Create profiles for personalised advertising	Yes	No
Purpose 4 - Use profiles to select personalised advertising	Yes	No
Purpose 5 - Create profiles to personalise content	Yes	No
Purpose 6 - Use profiles to select personalised content	Yes	No
Purpose 7 - Measure advertising performance	Yes	Yes
Purpose 8 - Measure content performance	Yes	Yes
Purpose 9 - Understand audiences through statistics or combinations of data from different sources	Yes	Yes
Purpose 10 - Develop and improve services	Yes	Yes
Purpose 11 - Use limited data to select content	Yes	Yes
Special Purpose 1 - Ensure security, prevent fraud, and fix errors	Notice Only	Notice Only
Special Purpose 2 - Deliver and present advertising and content	Notice Only	Notice Only
Special Purpose 3 - Save and communicate privacy choices	Notice Only	Notice Only
Feature 1 - Match and combine data from other data sources	Notice Only	Notice Only
Feature 2 - Link different devices	Notice Only	Notice Only
Feature 3 - Identify devices based on information transmitted automatically	Notice Only	Notice Only
Special Feature 1 - Use precise geolocation data	Yes	No
Special Feature 2 - Actively scan device characteristics for identification	Yes	No

To configure Legitimate Interest

On the Cookie Consent menu, go to the Templates tab. The Templates screen appears.
Select your IAB TCF 2.2 template from the list. The Template Details screen appears.
Navigate to the Preference Center tab.
Expand the Advanced Configuration section.
Enable or disable the Allow Legitimate Interest setting. This toggle will dynamically update the Banner and Preference Center texts to include or remove legitimate interest per TCF 2.2 policies.

Note:
The objection to Legitimate Interest can be displayed as a toggle switch or a button. The Show Object to Legitimate Interest as a button setting can be found in the Styling section of the Preference Center tab.
If you are disabling Legitimate Interest in your template, you may also need to make edits to the Vendor List. Specifically, you may want to disable Legitimate Interest and enable consent for all purposes.
1. On the Cookie Consent menu, select Vendors. The Vendor List screen appears.
2. Go to the IAB Vendor tab.
3. Select the version name you want to configure. The Vendor Details screen appears.
4. Use the checkbox in the column header to select all vendors from the list. The Manage Legal Basis button appears.
5. Click the Manage Legal Basis button. The Manage Legal Basis modal appears.
6. Use the checkboxes in the column header to select Consent for all purposes and deselect Legit. Interest for all purposes.
7. Click the Save button.
This will place the appropriate Publisher Restrictions on all purposes to process on Consent where flexible purposes are used. Publisher Restrictions are set in the tcData. Learn more here.
Publish the script for the changes to take effect.

Attention:

If you are overriding legal bases for all vendors, it could cause the Publisher Restrictions to enlarge the size of the eupubconsent-v2 cookie to a size that is incompatible with the browser. Disable any vendors to which you do not wish to signal consent or legitimate interest.

Consent & Preferences

Configuring Legitimate Interest for IAB TCF 2.2

To configure Legitimate Interest

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